UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

_______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JONATHAN C. WILLIAMS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE

CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on November 2 1

, 2015

JONATHAN C. WILLIAMS

PO Box 943

5 Shamrock St.

Stockbridge, MA 01262

(978) 505

- 50752 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ .................... 3

SUMMARY

................................ ................................ ................................ ..................... 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ............................ 4

BACKGROUND

................................ ................................ ................................ ........................... 5

BASIS FOR PETITION

................................ ................................ ................................ ................ 5

NAME AND ADDRESS OF PETITIONER

................................ ................................ ........ 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

JONATHAN C. WILLIAMS SEEKS EXEMPTION

................................ .............................. 7

THE EXTENT OF RELIEF JONATHAN C. WILLIAMS SEEKS AND

THE REASON JONATHAN C. WILLIAMS SEEKS THE RELIEF

................................ ........ 9

THE REASONS WHY GRANTING JONATHAN C. WILLIAMS ’ REQUEST

WOULD BE IN THE PUBLIC INTEREST

................................ ................................ ........ 1 0

THE REAS ONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY

................................ ................................ ...................... 1 2

CONCLUSION

................................ ................................ ................................ ............................. 1 9

A P P E N D I X A

................................ ................................ ................................ ............................... 2 0

A P P E N D I X B

................................ ................................ ................................ ............................... 2 13 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviatio n Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

V MC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer battery

RCV Radio Controlled vehicle4 SUMMARY

JONATHAN C. WILLIAMS seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to

operate an Unmanned Aircraft System pursuant to Section 333 of th e FAA Modernization and Reform

Act of 2012 (FMRA). This exemption will permit JONATHAN C. WILLIAMS to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and

photography for marketing, film sets, real estate phot ography, commercials, special events, including

weddings, and landscape topography over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is JONATHAN C. WILLIAMS, and I am a Private Pilot and drone operator (pilot) with

expertise and knowledge of video production and operating multiple types of UAS'S. JONATHAN C.

WILLIAMS, doing business as Big2Do Productions, also provides clients with the highest quality

digital content for use in their commercial, personal

, and non

- profit multimedia projects. JONATHAN

C. WILLIAMS has held a Pilot ’ s license for 37 years and has 20 years of professional video

experience. JONATHAN C. WILLIAMS is recognized as an expert in the field of Videography

.

The objective of JONATHAN C

. WILLIAMS ’ aerial video and photography operations is to provide

high quality imaging for a variety of commercial, public, and non

- profit uses, operating in locations

away from all obstacles and people at all times. JONATHAN C. WILLIAMS will also provide

knowledge of UAS and promote safe UAS operations.5 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs

JONATHAN C. WILLIAMS seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electro nic tablet or smart

phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2 pounds 14

ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum

speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of

approximately 42 knots. The DJI Phantom 3 and DJI Inspire 1UAs are equipped with four main rotors;

driven by Li thium Polymer battery powered electric motors.

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by JONATHAN C. WILLIAMS will

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft R egistration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Markings.

BASIS FOR PETITION

Petitioner, JONATHAN C. WILLIAMS, pursuant to the provisions of the Federal Aviation Regulations

(14 C.F.R. § 11.61) and the F AA Modernization and Reform Act of 2012 (FMRA), Section 333,

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to

commercially operate the DJI Phantom 3, DJI Inspire 1 UASs in the National Airspace System (NAS),

and fo r an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned

aircraft and its operation, JONATHAN C. WILLIAMS' operation of DJI Phantom 3 and DJI Inspire 1

UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Su bpart H.

Accordingly, JONATHAN C. WILLIAMS requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance

that only apply to aircraft with an airworthiness cert ificate.

JONATHAN C. WILLIAMS submits that the requested relief is proper since an equivalent level of

safety will be ensured. JONATHAN C. WILLIAMS will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the U ASs using the methods,

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and

DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, JONATHAN C. WILLIAMS will

document and maintain all maintenance rec ords for the DJI Phantom 3 and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and

limitations: Pilot in command, is requested by JONATHAN C. WILLIAMS to the extent necessary to6

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman

medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safely operate the DJI Phant om 3 and DJI Inspire 1 UASs in a

manner consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

JONATHAN C. WILLIAMS seeks relief from Section 91.7(a)

, entitled Civil aircraft airworthiness,

because the DJI Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, JONATHAN C. WILLIAMS submits that he

will ensure that the DJI Ph antom 3 and DJI Inspire 1UASs are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and tha t the aircraft are in

a condition for safe flight.

JONATHAN C. WILLIAMS also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 and DJI Inspire

1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio

communications telemetry data link, which downlinks from the UA to the GCS for active moni toring

of the flight path. This altitude information, combined with JONATHAN C. WILLIAMS operation of

the DJI Phantom 3 and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will

ensure a level of safety equivalent to Section 91.121

.

Additionally, JONATHAN C. WILLIAMS seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. JONATHAN C. WILLIAMS

submits that safety will not be affected by operation of the DJI Phantom 3 a nd DJI Inspire 1 UAs

during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with

enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of

intended landing and, assuming n ormal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, JONATHAN C. WILLIAMS provides the following information

in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

JONATHAN C. WILLIAMS

5 SHAMROCK STREET

PO BOX 943

STOCKBRIDGE, MA 01262

(978)

- 505

- 5075

Email: williamsjonathan08@gmail.com7

B. The Specific Sections Of 14 C.F.R. from Which JONATHAN C. WILLIAMS Seeks Exemption.

1. JONATHAN C. WILLIAMS Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, Subsections

(a) and (b) prescribe the following, in relevant part:

a. No person who holds a private pilot certificate may act as a pilot in command (PIC) of

an aircraft that is carrying passengers or property for compensation or hire; nor may that

person, for compensation or hire, act as PIC of an aircraft.

b. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection

with any business or employment if

—

i. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or property for compensation or hire.

2. JONATHAN C. WILLIAMS Seeks Exemption From The Requirements Of Section

91.7(a). Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. JON ATHAN C. WILLIAMS Seeks Exemption From The Requirements Of Section

91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

a. Each person operating an aircraft shall maintain the cruising altitude or flight level of

that aircraft, as the case may be, by reference to an altimeter that is set,

when operating

--

Below 18,000 feet MSL, to

—

i. The current reported altimeter setting of a station along the route and within 100

nautical miles of the aircraft;

ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this

section, the current reported altimeter setting of an appropriate available station;

iii. In the case of an aircraft not equipped with a radio, the elevation of the departure

airport or an appr opriate altimeter setting available before departure.

4. JONATHAN C. WILLIAMS Seeks Exemption From The Requirements Of Section

91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No p erson may begin a flight in a rotorcraft under VFR conditions unless (considering wind

and forecast weather conditions) there is enough fuel to fly to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at l east 20 minutes.

5. JONATHAN C. WILLIAMS Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner

or operator of an aircraft

— (a) Shall have that aircraft insp ected as prescribed in subpart E of this part and shall between

required inspections, except as provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter[.]

6. JONATHAN C. WILLIAMS Seeks Exemption From Th e Requirements Of Section

91.407(a)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that

has undergone maintenance, pre ventive maintenance, rebuilding, or alteration unless

-- (1) It

has been approved for return to service by a person authorized under § 43.7 of this chapter [.]8

7. JONATHAN C. WILLIAMS Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a )(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless,

within the preceding 12 calendar months, it has had

-- (1) An annual i nspection in accordance with part 43 of this chapter and has been approved for

return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of

this cha pter.

8. JONATHAN C. WILLIAMS Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

a. Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph

(b) of this section: Records of the maintenance, preventive maintenance, and alteration

and records of the 100

- hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and each engine,

propeller, rotor, and appliance of an aircraft. The records must include

—

i. A description (or reference to data acceptable to the Adminis trator) of the work

performed; and

ii. The date of completion of the work performed; and

iii. The signature, and certificate number of the person approving the aircraft for

return to service.

Records containing the following information:

1. The total time in service o f the airframe, each engine, each propeller, and

each rotor.

2. The current status of life

- limited parts of each airframe, engine, propeller,

rotor, and appliance.

3. The time since last overhaul of all items installed on the aircraft which

are required to be o verhauled on a specified time basis.

4. The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

5. The current status of applicab le airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

re quired.

6. Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

b. The owner or operator shall retain the following records for the periods p rescribed:

i. The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work is

performed.

ii. The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

iii. A list of defects furnished to a registered owner or operator under § 43.11 of this9 chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service.

C. The Extent Of Relief JONATHAN C. WILLIAMS Seeks And The Reason JONATHAN C.

WILLIAMS Seeks The Relief.

1. Extent Of Relief JONATHAN C. WILLIAMS Seeks And The Reason JON ATHAN C.

WILLIAMS Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding a private pilot or highe r

level certificate, as well as a current and valid airman medical certificate, and who has met

certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations

for compensation or hire.

This relief is requested since the limi tations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if: (1) The flight is only incidental to that business or employment; and

(2) T he aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, JONATHAN C. WILLIAMS submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS o r

DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements,

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 or DJI Inspire 1

UAS in a manner consistent with the operations specifications as descr ibed in this exemption,

including evasive and emergency maneuvers, as well as maintaining appropriate distances from

people, vessels, vehicles and structures.

Further, JONATHAN C. WILLIAMS submits that all flights of the DJI Phantom 3 and DJI

Inspire 1 UA Ss, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to JONATHAN C. WILLIAMS ’ business; and (2) will not carry passengers or

property for compensation or hire.

2. Extent Of Relief JONATHAN C. WILLIAMS Seeks And The Reason JONATHAN C.

WILLIAMS Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow JONATHAN C. WILLIAMS to determine that the DJI Phantom 3 and DJI

Inspire 1 UASs are in a irworthy condition prior to every flight by ensuring that the UAS is in

compliance with the operating documents (i.e., JONATHAN C. WILLIAMS Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual).

JONATHA N C. WILLIAMS seeks the requested relief because the DJI Phantom 3 and DJI

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H. Therefore, JONATHAN C. WILLIAMS will ensure that the DJI Phantom 3 and DJ I

Inspire 1 UASs are in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction

Manual) prior to every flight, and further, determine that the aircraft are i n condition for safe

flight, as stated in the conditions and limitations below.

3. Extent Of Relief JONATHAN C. WILLIAMS Seeks And The Reason JONATHAN C.

WILLIAMS Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may b e required to allow flight

operations of the DJI Phantom 3 and DJI Inspire 1 UASs, which utilize a barometric pressure

sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude10

information from the UA to the PIC at the grou nd control station (GCS). Since the FAA requires

that any altitude information concerning UAS operations be reported to air traffic control (ATC)

in feet above ground level (AGL), JONATHAN C. WILLIAMS seeks the requested relief

because the DJI Phantom 3 an d DJI Inspire 1 UA ’ s altimeter may be set on the ground to zero

feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is

sought to t he extent necessary to comply with the applicable conditions and limitations stated

below. As more fully set forth herein, an equivalent level of safety will be maintained since the

DJI Phantom 3 and DJI Inspire 1 UAs are equipped with a barometric pressur e sensor and GPS

equipment, which automatically ensures that a ground level pressure setting will be established

prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up

display of the GCS.

4. Extent Of Relief JONATHAN C. WILLIAMS Seeks And The Reason JONATHAN C.

WILLIAMS Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered D JI Phantom 3 and DJI

Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual

flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly aft er that for at least 4.5 minutes. JONATHAN C.

WILLIAMS seeks the requested relief because without an exemption from Section 91.151(b),

the flight time duration of the battery powered DJI Phantom 3 and DJI Inspire 1 UAs will

severely constrain the practical ity of any aerial video or still photo flight operations that

JONATHAN C. WILLIAMS proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 and DJI

Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating documents, and JONATHAN C.

WILLIAMS proposed operating limitations, ensure that JONATHAN C. WILLIAMS will

safely operate the battery powered DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours

in visual meteorological con ditions (VMC), under visual flight rules (VFR), with enough

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief JONATHAN C. WILLIAMS Seeks And The Reason JONATHAN C.

WILLIAMS Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And

91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, JONATHAN C. WILLIAMS requests

relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 UASs do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspi re 1

UASs meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate.

Accordingly, JONATHAN C. WILLIAMS will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the method s, techniques, and

practices prescribed in the UAS operating documents (i.e., JONATHAN C. WILLIAMS Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1

Instruction Manual). Furthermore, JONATHAN C. WILLIAMS will document a nd maintain all

maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs.11

D. The Reasons Why Granting JONATHAN C. WILLIAMS Request Would Be In The Public

Interest: That Is, How It Would Benefit The Public As A Whole.

Granting the present Peti tion will further the public interest by allowing JONATHAN C.

WILLIAMS to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, and landscape over certain areas of the United States.

Additionally, u se of the DJI Phantom 3 and DJI Inspire 1 UASs will decrease congestion of the

NAS, reduce pollution, crashes and accidents caused by pilot error and provide significant

benefits to the economy. Notably, the benefits of JONATHAN C. WILLIAMS ’ proposed

opera tion of the DJI Phantom 3 and DJI Inspire 1 UASs will be realized without implicating

any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and serve as a safe, efficie nt,

and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery.

By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption

allowing the use of a DJI Phantom 3 or DJI Inspire 1 UAS wo uld reduce the amount of manned

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and

property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3

and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of

manned aircraft conducting aerial video and photography missions would result in fewer

aircraft that must be handled by air traffic control during the ground, takeoff, departure,

arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 and DJI

Inspire 1 U ASs.

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UASs, instead

of manned aircraft, will greatly benefit the public by drastically reducing the levels of air

and noise pollution generated during traditional aerial video and sti ll photography flight

operations. By using battery power and electric motors, the DJI Phantom 3 and DJI Inspire 1

UASs produce no air pollution, and is the most viable environmentally conscious alternative to

the cabin class, six cylinder internal combusti on engine aircraft that are typically utilized for

aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded

aviation fuel. The DJI Phantom 3 and DJI Inspire 1 UAs, while reducing the carbon footprint of

aerial acquisitions

, also eliminates noise pollution, as the UAs are propelled by battery powered

electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 and DJI Inspire 1 UASs to perform aerial acquisitions, the

substantial risk to life and p roperty in the air and on the ground, which is usually associated

with traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI

P hantom 3 and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds

7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3

inches respectively, widths of 16 inches and 17.7 inches respectively, and wit h no fuel on

board), has less physical potential for collateral damage to life and property on the ground, and

in the air, compared to the manned aircraft that typically conduct similar operations (weighing

approximately 6,000 pounds with a wingspan of app roximately 42 feet, a length of 34 feet, and

a fuel capacity of 180 gallons).12

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 and DJI

Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phanto m 3 and DJI Inspire 1 UASs are also an

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the DJI Phantom 3 and DJI Inspire 1 UASs will allow United States based

companies, like Big2Do Productions, to remain competitive and contribute to growth of the

U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental

Protection Agency ( “ EPA ” ) regulatory actions phasing out leaded aviation fuels, U.S. owned

and operated companies must adopt new and alternative technology in order to remain

competitive. Operating the battery powered DJI Phantom 3 and DJI Inspire 1 UASs is one such

technology that not only allows companies greater operational flexibility compared to manned

aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.

By operating the DJI Phantom 3 and DJI Inspire 1 UASs, companies such as JONATHAN C.

WILLIAMS doing business as Big2Do Productions, can remain competitive and profitable, and

therefore, provide greater job stability to employees and contractors, which will ultimately

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies,

through commercial use of the DJI Phantom 3 and DJI In spire 1 UASs, provides a stable

workforce that increases consumer spending; improves local, state, and federal tax revenues;

and allows companies to invest in research and development in order to remain competitive

both in the United States and abroad.

4. Th ere Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

JONATHAN C. WILLIAMS' proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs

would not implicate any privacy issues. Specifi cally, the DJI Phantom 3 and DJI Inspire 1

UASs will be operated only in compliance with operating documents (i.e., JONATHAN C.

WILLIAMS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI

Inspire 1 Instruction Manual) which requir es property owner involvement as well as local law

enforcement notification, and in accordance with the Federal Aviation Regulations, including

the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule

From Which JONATHAN C. WILLIAMS Seeks Exemption.

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAs Meet The Conditions Of The

FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, JONATHAN C.WILLI AMS ’ operation of the DJI Phantom

3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides

authority for a UAS to operate with out airworthiness certification and sets forth requirements

for considering whether a UAS will create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

a. In General.

-- Notwithstanding any other requirement of this subtitle, and not later than

180 days after the date of enactment of this Act, the Secretary of Transportation shall13 determine if certain unmanned aircraft systems may operate safely in the nati onal

airspace system before completion of the plan and rulemaking required by section 332

of this Act or the guidance required by section 334 of this Act.

b. Assessment of Unmanned Aircraft Systems.

-- In making the determination under

subsection (a), the Secr etary shall determine, at a minimum

—

i. Which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, operational capability, proximity to airports and populated areas,

and operation within visual line of sight do not create a ha zard to users of the

national airspace system or the public or pose a threat to national security; and

whether a certificate of waiver, certificate of authorization, or airworthiness

certification under section 44704 of title 49, United States Code, is req uired for

the operation of unmanned aircraft systems identified under paragraph (1).

c. Requirements for Safe Operation.

-- If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system

, the Secretary shall establish requirements for the safe operation of such aircraft systems

in the national airspace system.

In seeking this exemption, JONATHAN C. WILLIAMS submits that the DJI Phantom 3

and DJI Inspire 1 UASs can operate safely in the N AS pursuant to FMRA Section 333,

as demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1

UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

i. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs

Demonstrate Its Safe Characteristics.

The DJI Phantom 3 and DJI Inspire 1 UASs do not create a hazard to users of

the NAS or the public, or otherwise pose a threat to national security considering

its size, weight, speed, and operational cap ability.

ii. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs.

The DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheet, attached

hereto as Appendix A and B, set the technical specifications of the DJI Phantom

3 and DJI Inspire 1 UASs forth.

iii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous Flight And

Navigation Modes Enable The UASs To Remain Within A Defined

Operational Area.

The DJI Phantom 3 and DJI Inspire 1 UASs may be operated in both manual and

fully autonomous flight m odes. A complete description of the flight and

navigational modes of the DJI Phantom 3 and DJI Inspire 1 UASs is provided at

pages 25

- 35 of the DJI Phantom 3 and pages 12

- 16 and 45

- 50 of the DJI Inspire

1 User Manuals, attached hereto as Exhibit C and D.

iv. The DJI Phantom 3 and DJI Inspire 1 UASs Are Designed For Automatic

Return To Home Point Or Hover In The Event Of Loss Of The Control

Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 and DJI Inspire 1 UAs will

remain stationary, in flig ht, for 3 seconds or more. If, after 3 seconds, the DJI

Phantom 3 and DJI Inspire 1 UAs do not reacquire control link data from the

GCS, the UAs will assume that the Control Link is lost and the UAs will return

to the home position (i.e., failsafe mode) vi a GPS, and will descend to the

takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are14 set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15

of the DJI Phantom 3 and DJI Insp ire 1 User Manuals, attached hereto as Exhibit

C and D.

v. The DJI Phantom 3 and DJI Inspire 1 GCS And It ’ s Operation.

A complete description of the operation and specifications of the DJI Phantom 3

and DJI Inspire 1 GCS and flight control software is provide d at pages 32

through 43 of the DJI Phantom 3 User Manual and pages 40 through 47 of the

DJI Inspire 1 User Manual. DJI Phantom 3 and DJI Inspire 1 User Manuals are

attached hereto as Exhibits C and D.

vi. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 U ASs Are Limited

To The Line Of Sight Of A Certificated Pilot in Command With A Safety

Observer.

JONATHAN C. WILLIAMS will only utilize certificated pilots who possess a

current and valid airman medical certificate to act as a pilot in command (PIC)

of the DJI Phantom 3 and DJI Inspire 1 UASs. Additionally, a safety observer

will assist all pilots during flight time.

vii. Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, JONATHAN C. WILLIAMS proposes to

commercially operate DJI Phantom 3 and DJI Inspire 1 UASs for the special

purpose of conducting aerial video and photography over certain areas of United

States, pursuant to the following specific operating limitations:

1. Ope rations authorized by this grant of exemption will be limited to the

following aircraft described in the operating documents, rotorcraft UASs

weighing less than 55 pounds maximum gross weight: DJI Phantom 3

and DJI Inspire 1 Unmanned Aircraft Systems. Prop osed operations of

any other aircraft will require a new petition or a petition to amend this

grant.

2. UAS operations under this exemption will be limited to conducting

operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above

ground level (AGL), as indicated by the procedures specified in the

operating documents unless a special request is made and approved by

ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC

at all times. This requires the PIC to be able to use human vision unaided

by any device other than corrective lenses, as specified on the PIC ’ s

FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is

not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used

to satisfy the VLOS requirement as long as the PIC always maintains

VLOS capability. The SO and PIC must be able to communicate verbally

at all times. Electronic messaging or texting is not permitted during

flight operations. The PIC must be designated before the flight and

cannot transfer his or her designation for the duration of the flight. The

PIC must ensure that the SO can perform the functions prescribed in the15 operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with

seeing and avoiding other air traffi c and other ground based

obstacles/obstructions and is not permitted to operate the camera or other

instruments.

9. The operating documents and the grant of exemption must be accessible

during UAS operations and made available to the Administrator upon

reque st. If a discrepancy exists between the conditions and

limitations contained in the grant of exemption and the procedures

outlined in the operating documents, the conditions and limitations

contained in the grant of exemption take precedence and must be

f ollowed. Otherwise, the operator must follow the procedures as outlined

in its operating documents. The operator may update or revise its

operating documents. It is the operator ’ s responsibility to track such

revisions and present updated and revised docum ents to the

Administrator upon request.

The operator must also present updated and revised documents if it

petitions for extension or amendment to the grant of exemption. If the

operator determines that any update or revision would affect the basis

upon w hich the FAA granted the exemption, then the operator must

petition for amendment to its grant of exemption. The FAA ’ s UAS

Integration Office (AFS

- 80) may be contacted if questions arise

regarding updates or revisions to the operating documents.

10. Prior to e ach flight the PIC must inspect the UAS to ensure that it is in a

condition f or safe flight. If the inspection reveals a condition that

affects the safe operation of the UAS, the aircraft is prohibited from

operating until the necessary maintenance has b een performed and the

UAS is found to be in a condition for safe flight. The Ground Control

Station must be included in the preflight inspection. All maintenance and

alterations must be properly documented in the aircraft records.

11. Any UAS that has undergon e maintenance or alterations that affect the

UAS operation or flight characteristics, e.g. replacement of a flight

critical component, must undergo a functional test flight. The PIC who

conducts the functional test flight must make an entry in the aircraft

records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer ’ s ai rcraft/component,

maintenance, overhaul, replacement, inspection, and life limit

requirements.

14. The operator must carry out its maintenance, inspections, and record

keeping requirements, in accordance with the operating documents.

Maintenance, inspection, a lterations, and status of replacement/overhaul

component parts must be noted in the aircraft records, including total

time in service, description of work accomplished, and the signature of

the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all16 manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between

inspections.

17. The PIC must p ossess at least a private pilot certificate and at least a

current third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the

operator ’ s qualification criteria and demonstrates the ability to safely

operate the UAS in a manner consistent with how the UAS will be

operated under the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures. PIC qualification flight hours must be logged in a

manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of

training the operator ’ s PICs are permitted under the terms of the

exemption. However, training operations may only be conducted during

dedicated training sessions. During traini ng, proficiency, and experience

building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with

appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

19. UAS ope rations may not be conducted during night, as defined in 14

C.F.R. § 1.1. All operations must be conducted under visual

meteorological conditions (VMC). If flight at night is required, a special

request will be made at the FAA office closest to proposed ar ea of

operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference

point as denoted on a current FAA

- published aeronautical chart unless a

letter of agreement with that airport ’ s management is obtained, and the

operation is conducted in accordance with a NOTAM as required by the

operator ’ s COA. The letter of agreement with the airport management

must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000

feet horizontally from a cloud or when visibility is less than 3 statute

miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to

a pre

- determined location within the planned operating area and land or

be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

24. The PIC is prohibited from begi nning a flight unless (considering wind

and forecast weather conditions) there is enough power to fly at normal

cruising speed to the intended landing point and land the UA with 25%

battery power remaining.

25. The operator must obtain an Air Traffic Organiz ation (ATO) issued

Certificate of Waiver or Authorization (COA) prior to conducting any

operations under the grant of exemption. This COA will also require the

operator to request a Notice to Airman (NOTAM) not more than 72 hours17 in advance, but not less t han 48 hours prior to the operation. All

operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and

potential transponder requirements.

26. All aircraft operated in accordance w ith the exemption must be identified

by serial number, registered in accordance with 14 C.F.R. part 47, and

have identification (N

- Number) markings in accordance with 14 C.F.R.

part 45, Subpart C. Markings must be as large as practicable.

27. Before conducti ng operations, the radio frequency spectrum used for

operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91 .9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time

the UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

29. The UA must remain clear and yiel d the right of way to all manned

aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or

vehicle.

31. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator

trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from the UA and/or debris in the

event of an accident. The ope rator must ensure that

nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations

must cease immediately and/or;

b. The aircraft is ope rated near vessels, vehicles or structures where

the owner/controller of such vessels, vehicles or structures has

granted permission and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it

does not p resent an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential

persons do not present an undue hazard to those persons per §

91.119(a).

32. All operations shall be conducted over private or controlled

- access

property with permis sion from the land owner/controller or authorized

representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable

COA must be reported to the FAA's UAS Integration Office (AFS

- 80)

within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions c ontained on the

NTSB Website: www.ntsb.gov.18

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would

Not Adversely Affect Safety.

JONATHAN C. WILLIAMS submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI

Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum

flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3

or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Considering JONATHAN C. WILLIAMS ’ proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the

airmanship skills necessary to safely operate the DJI Phan tom 3 or DJI Inspire 1 UAS,

JONATHAN C. WILLIAMS submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for

JONATHAN C. WILLIAMS ’ specific proposed flight operat ions.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161). JONATHAN C. WILLIAMS will not allow any

PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, by

meeting minimum flight

- hour requirements or the DJI P hantom 3 or DJI Inspire 1 UAS training

and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriat e distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R.

§ 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption). In addition to the hour requirements, the PIC must accomplish 3

takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exempt ion Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of

safety during JONATHAN C. WILLIAMS ’ proposed operations. The Administrator has held

that pr ior documented flight experience that was obtained in compliance with applicable

regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose

of motion picture fi lming (or similar operations), the PIC must have accumulated and logged, in

a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot

including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operat ions

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption. For clarification, the FAA considers these minimum hou r requirements to

be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10

hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS

rotorcraft time. In addition to the hour requirements, t he PIC must accomplish 3 takeoffs and

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum,

the flight hour requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner ’ s proposed operations. The19

FAA also finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and experience

building fl ights can also be conducted under the grant of exemption to accomplish the required

flight time. During training, proficiency, and experience

- building flights the PIC is required to

operate the UA with appropriate distances in accordance with 14 C.F.R 91.1 19.

Exemption No. 11138 at page 15.

Accordingly, JONATHAN C. WILLIAMS will ensure safe operations by not allowing any PIC

to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, by

meeting minimum flight

- hour and currency req uirements, that the PIC is able to safely operate

the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structure s.

CONCLUSION

JONATHAN C. WILLIAMS seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit

safe operation of the DJI Phantom 3 and DJI Inspire 1 UASs commercially, without an

airworthiness certificate, for the limited purpose of conducting aerial vid eo and photography

over certain areas of the United States. By granting this Petition, the FAA Administrator will be

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while

also advancing the interests of the public, by allowing JONATHAN C. WILLIAMS to safely,

efficiently, and economically operate the DJI Phantom 3 and DJI Inspire 1 UASs commercially

within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, JONATHAN C. WILLIAMS

respectfully requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2)

, and 91.417(a) & (b), and permit JONATHAN C.

WILLIAMS to operate the DJI Phantom 3 and DJI Inspire 1 UASs commercially for the

purpose of conducting aerial video and photography over certain areas of the United States.

Dated: November 2 1

, 2015

Submitted by

/ J O N A T H A N C

. W I L L I A M S /

JONATHAN C. WILLIAMS20 APPENDIX

– A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

JONATHAN C. WILLIAMS only utilizes safe and reliable UASs. DJI is an industry leader in small

UAS production. DJI UASs are loaded with ground breaking software enabling the user to set

parameters which will not allow flight into controlled airspace. Parame ters can also be set to limit flight

to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set

distance. In addition, DJI software provides real

- time altitude and location information to the PIC via

the linked mo nitor (smart phone/tablet devices)

DJI Phantom 3

1.1. Aircraft

1.1.1. Supported Battery

– DJI 6000AH LiPo Battery

1.1.2. Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.3. Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m

1.1.4. Max Yaw Angular V elocity

- 200/s

1.1.5. Max Tilt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s

1.1.6. Max Descent Speed

– 2m/s

1.1.7. Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.2. Gimbal

1.1.1. Working Current

– Static: 750mA; Dynamic: 900mA

1.1.2. Control Accuracy

- ± 0.03

1.1.3. Controllable Range

– Pitch:

- 90

- 0

1.1.4. Maximum Angular Speed

– Pitch: 90/s

1.3. Camera

1.1.1. Operating Temperature Range

- 32F

- 104F (0C

- 40C)

1.1.2. Sensor Size

– 1/2.3 ”

1.1.3. Effective Pixels

– 14M

1.1.4. Resolution

– 4384x3288

1.1.5. HD Video Recording

– 1080p30 & 720p

1.1.6. Recording Field of View

- 110/8521 APPENDIX

– B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

JONATHAN C. WILLIAMS only utilizes safe and reliable UASs. DJI is an industry leader in small

UAS production. DJI UASs are loaded with ground breaking software enabling the user to set

parameters which will not allow flight into controlled airspace. Parame ters can also be set to limit flight

to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set

distance. In addition, DJI software provides real

- time altitude and location information to the PIC via

the linked mo nitor (smart phone/tablet devices)

DJI Inspire 1

1.1. Aircraft

1.1.1. Model

– T600

1.1.2. Weight (Battery Included)

– 6lbs 7.5291oz (2935g)

1.1.3. Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m

1.1.4. Max Angular Velocity

– Pitch: 300 0 /s; Yaw: 150 0 /s

1.1.5. Max Tilt Angle

- 35 0

1.1.6. Max Ascent Speed

– 5m/s

1.1.7. Max Descent Speed

– 4m/s

1.1.8. Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED)

1.1.9. Max Flight Altitude

– 4500m

1.1.10. Max Wind Resistance

– 10m/s

1.1.11. Max Flight Time

– Approximately 18 minutes

1.1.12. Motor Model

– DJI 3510

1.1.13. Propeller Model

– DJI 1345

1.1.14. Operating Temperature Range

– 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

1.1.15. Dimensions

– 17 1⁄4” x 17 3⁄4” x 12 ”

1.2. Gimbal

1.1.1. Model

– ZENMUSE X3

1.1.2. Output Power (with camera)

– Static: 9W; In Motion: 11W

1.1.3. Operating Current

– Static: 750mA; In Motion: 900mA

1.1.4. Angular Vibration Range

- ± 0.03 0

1.1.5. Mounting

– Detachable

1.1.6. Controllable Range

– Pitch:

- 90 0 to +30 0 ; Pan: ± 320 0

1.1.7. Mechanical Range

– Pitch:

- 125 0 to 45 0 ; Pan: ± 330 0

1.1.8. Max Controllable Speed

– Pitch: 120 0 /s; Pan: 180 0 /s

1.3. Transmitter

1.1.1. Name

– C1

1.1.2. Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz

1.1.3. Communicating Distance (unobstructed)

– 2000m

1.1.4. Output Power

– 9W

1.1.5. Operating Temperature Range

- 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

1.1.6. Battery

– 600mAh LiPo 2S

All specifications can be found in the attached user manual or at

http://www.dji.com/product/inspire

- 1/spec